People v. Boose

Defendant was convicted, after jury trial, of unlawful violation of order of protection. Defendant was deprived of a fair preliminary inquiry into his pro se claims of ineffective assistance of trial counsel. State's participation in hearing was more than offer of concrete and easily verifiable facts, and thus rendered hearing adversarial at which Defendant was required to argue against both defense counsel and the State. Because hearing became adversarial, Defendant was required, without clearly and formally waiving his right to counsel, to represent himself and argue merits of each claim. (BURKE and HUTCHINSON, concurring.)